Jesus De Los Santos, Jr., Individually and as Representative of the Estate of Jesus Francisco De Los Santos, and Juan De Los Santos, Individually v. Ford Motor Company and Marco Anthony Soliz, Jr. (Cross-Appellant)

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ACCEPTED 04-14-00562-cv FOURTH COURT OF APPEALS SAN ANTONIO, TEXAS 4/6/2015 9:11:16 AM KEITH HOTTLE CLERK NO. 04-14-00562-CV FILED IN IN THE TEXAS COURT OF APPEALS FOR THE FOURTH DISTRICT 4th COURT OF APPEALS SAN ANTONIO, TEXAS SAN ANTONIO, TEXAS 4/6/2015 9:11:16 AM KEITH E. HOTTLE * * * * * Clerk JESUS DE LOS SANTOS, JR., Individually and as Representative of the ESTATE OF JESUS FRANCISCO DE LOS SANTOS, and JUAN DE LOS SANTOS, Appellants; and MARCO ANTHONY SOLIS, JR., Cross-Appellant, v. FORD MOTOR COMPANY, Appellee * * * * * On Appeal from the 79th Judicial District Court Jim Wells County, Texas Trial Court Cause No. 11-08-50394-CV * * * * * APPELLANTS’ UNOPPOSED MOTION FOR LEAVE TO FILE POST-SUBMISSION LETTER BRIEF * * * * * THE HONORABLE JUSTICES OF THE COURT: Jesus De Los Santos, Jr. Individually and as Representative of the Estate of Jesus Francisco De Los Santos and Juan De Los Santos, Appellants, respectfully presents this motion requesting leave to file the post-submission letter brief attached hereto as Exhibit A, which addresses record citations relevant to certain important factual questions asked by the Court during the recent oral argument in this matter. In support of this motion, Appellants would show the Court as follows: 1. This appeal was submitted on oral argument on Thursday, March 26, 2015. 2. The case involves complicated technical issues about product specifications, metallurgy, and accident reconstruction. 3. During the course of the oral argument, the Court had several questions about these technical issues, in particular, questions about Ford’s specifications for “hardness” and other applicable matters related to planned output for Ford axles. Such matters are difficult to succinctly explain in the span of a short oral argument and require a review of several portions of the technical and expert testimony in the context of the record. Since these factual matters about the content of the record are central to the issues raised in this appeal, Appellants request leave to file the attached post-submission letter brief to help guide the Court to the relevant portions of the record as they pertain to specifications and planned output for Ford axles. 4. Certificate of Conference: On April 2, 2015, the undersigned conferred via email with Allyson Ho, lead appellate counsel for Appellee Ford Motor Company, regarding the relief requested in this motion. Ms. Ho responded that Ford takes no position regarding the requested relief. Therefore, this motion is filed as UNOPPOSED. Respectfully submitted, By: ________________________________ Brendan K. McBride State Bar No. 24008900 Brendan.mcbride@att.net THE MCBRIDE LAW FIRM Of Counsel to GRAVELY & PEARSON, LLP 425 Soledad, Suite 620 San Antonio, Texas 78205 (210) 472-1111 Telephone (210) 881-6752 Facsimile 2 And Jeffrey G. Wigington State Bar No. 00785246 jwigington@wigrum.com R. Reagan Sahadi State Bar No. 24042369 rsahadi@wigrum.com WIGINGTON RUMLEY DUNN & BLAIR, LLP 123 N. Carrizo St. Corpus Christi, Texas 78401 (361) 881-7500 (361) 884-0487 (Facsimile) COUNSEL FOR APPELLANTS, JESUS DE LOS SANTOS, JR. INDIVIDUALLY AND AS REPRESENTATIVE OF THE ESTATE OF JESUS FRANCISCO DE LOS SANTOS AND JUAN DE LOS SANTOS 3 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document has been forwarded on this 6th day of April, 2015 to Appellee’s counsel of record, Allyson Ho and Cross-Appellant Marco Soliz, Jr.’s lead appellate counsel, Lupita Aguilar, by electronic service through Texas.gov. ____________________________________ Brendan K. McBride 4